Information for Study Center Directors and Staff

UC faculty and staff have access to student information only for legitimate use in the completion of UC responsibilities. As faculty and staff members performing a function on behalf of UC, SC Directors and staff have a legal responsibility under FERPA (Family Educational Rights and Privacy Act) and the California Information Practices Act (IPA) to protect the confidentiality of student educational records in their possession.

UC policies applying to the disclosure of information from student records are contained in the UC Policies Applying to Campus Activities, Organizations, and Students, a UC systemwide document from the Office of the President. EAP's Student Information Release Matrix will help SC Directors answer requests for disclosure of information from a student's record.

In compliance with US federal and California state laws, students may choose to exercise their right to restrict disclosure of any or all of their personally identifiable information (directory information and confidential information) when they apply to EAP. Students who choose to restrict disclosure of information will be flagged with a confidentiality icon in MyEAP. The confidentiality icon can be easily viewed next to the student's full name in a Quick List mode. This confidentiality mark restricts disclosure of any information to third parties, including parents. Although UC encourages students to give UC officials consent to release information to parents, the only exception that allows UC faculty or staff to share information with parents (without the recent consent of a student) is in the case of a safety or health emergency. UC treats all students as adults whether they are financially dependent or not, and UC treats parents like any member of the public in terms of what information UC officials can share with them. There are two types of educational records (personally identifiable information) as defined under FERPA: directory information and confidential information.

UC may release certain information (directory information) about students without their permission. These items are listed in the Student Information Release Matrix. Students who have requested a higher confidentiality level are exercising their right to privacy. Technically, EAP cannot admit they are in the Program. There are few exceptions to this rule: disclosure to UC and/or host institution staff and faculty when such information is relevant and necessary in the performance of their UC duties, disclosure during a health or safety emergency, disclosure when the student specifically authorizes release of information, disclosure to officials in the UC Office of the President or the UC Office of the General Counsel, or disclosure to comply with a subpoena.

The Study Center may disclose directory (public) and non-directory (confidential) information about a student who has blocked the release of information only after the student gives specific authorization in writing to do so. If a parent requests information or wants to discuss a student's personal situation, the SC Director should explain that the release of personally identifiable information (directory and confidential information) has been blocked and that an exception cannot be made, even for parents, without a student's written authorization. Parents may generally be sympathetic if they understand that obtaining written consent from the student is a formality to comply with FERPA and other privacy laws. The student should use the Release of Student Information to a Third Party Authorization form. The Study Center should keep a copy of such a statement as the record or the disclosure, and send UOEAP the original.

Students who have blocked the release of information may not be included on address lists circulated by the Study Center unless such students specifically grant permission.

When students apply for EAP and restrict the release of any or all of the categories of their personally identifiable information, it is possible that they may not fully understand the implications of their choice. Students may rescind their original instructions using the Authorization to Release Items of Public Information form to allow the disclosure of public information or the Release of Student Information to a Third Party Authorization form to allow the release of specific information. The original of this form should be forwarded to UOEAP as part of the student's permanent record.

600.01 Communications, Confidential

The SC Director may consider it necessary to write an "in confidence" letter to UOEAP on a matter relating to a student's health that is intended as background information for UOEAP's Operations or Academic Specialists and/or a physician, psychiatrist, or psychologist advising the SC Director or student concerning a specific problem. If such a letter is marked "in confidence," it will be stapled closed when filed and/or shared with a professional or paraprofessional acting in his or her capacity to assist the student. Copies of confidential e-mail or faxes and telephone call notes will be handled on the same basis.

All materials, whether they are placed in the student's file or not, are not considered sole-possession records, are legally part of the student's file (even when stored elsewhere). The student's file is subject to the student's review at his or her request in accordance with California and federal laws. However, the laws do not mandate that records be made or kept in every instance, so the SC Director may wish to exercise judgment in this regard. Legally, records may be discarded at any time up to the student's request to review his or her file. From the moment of the request, nothing may be discarded and all materials must be gathered for the student to review, regardless of where they have been stored.

600.02 Requests for Disclosure of Information from Student Records

There have been rare cases in the past when a host government authority has requested the SC Director to release information other than directory (public) information concerning a student (see Student Information Release Matrix).

If a request comes to the SC Director to release confidential information, he or she should immediately notify the student and explain the processes, as noted below, which will be followed in responding to the request.

Before releasing records, the SC Director should immediately consult with:

1. Persons at the host university who are responsible for student personal and legal affairs.

2. The legal officer of the nearest U.S. consulate or embassy.

3. The legal officer of the closest consulate or embassy of the student's country of citizenship (if he or she is not an American citizen).

The key question for the SC Director to address with these officials should be the degree to which the UC procedures, as outlined, are in conflict with the policies, regulations, and/or laws of the host institution and host country, and whether any relevant protocols exist between the U.S. and the host government (and possibly a third country if the student is a foreign national).

On the basis of the procedures and consultations mentioned above, the SC Director should contact the appropriate Regional Director at UOEAP to:

1. Report the response he or she recommends be made to the host government's request.

2. Receive approval from UOEAP as to the response. If the response recommended by the SC Director is contrary to UC procedures, UOEAP will consult with the UC General Counsel's Office and advise accordingly.

3. Come to a mutually agreed-upon conclusion as to how to reply to the request.

The SC Director should notify the student immediately using the Disclosure of Student Records form whether records were disclosed. The SC Director should send a copy of this form to UOEAP.

600.03 Notification of Judicial Order or Subpoena

In case the SC Director receives a judicial order or subpoena for records (see Notification of Judicial Order of Subpoena), the consultations and procedures outlined in the previous section should be followed.

605. CORRESPONDENCE

605.00 Correspondence: Mail Handling

Although administrative procedures and assignments in UOEAP are under continual review, staff responsibilities are organized generally along regional and functional lines. UOEAP provides staff and regional responsibility charts and an organizational chart on EAP's Contact Information web page.

UOEAP is working to handle as many documents as possible in electronic formats. When it is necessary to send mail, the package usually contains correspondence from several staff members. Important or time-sensitive materials are sent individually as needed. Correspondence sent from Study Centers to UOEAP, even though directed to different persons on the staff, should be sent in one envelope to save mailing costs and to expedite distribution and review. Personal or confidential correspondence should be sent in a separate envelope marked appropriately for the intended recipient.

605.01 Electronic Mail

Electronic mail is an important communication tool for conducting UCEAP business. E-mail also comprises part of the business records of UCEAP to the same extent as printed materials.

All Study Centers are equipped with computers, Internet and e-mail access for the SC Director and staff. During orientation, SC Directors should remind students to keep their e-mail addresses (and other contact information) updated in MyEAP throughout the program to facilitate timely communication for routine program business or in the event of an emergency. (See EAP's E-mail Policy for Messages Containing Information on Specific Students.)

Given that so much information (both confidential and non-confidential) about students circulates within UOEAP, the Campus EAP Offices, the Study Center, campus Student Health Services, Counseling and Psychological Services, the Office of the General Counsel, etc., EAP must strenuously attempt to protect student privacy when communicating with or about students, even though both the nature of e-mail and the public character of the University's business make e-mail less private than users may anticipate. Students rely on UCEAP to protect their privacy.

Best Practices

Exercise extreme caution in using e-mail to communicate confidential or sensitive matters as UC policies indicate that e-mail, whether or not created or stored on University equipment, may constitute a University record subject to disclosure under the California Public Records Act or other laws, or as a result of litigation.

The practice of e-mail forwarding deprives e-mail senders of privacy. Make sure that before forwarding a message to another e-mail recipient you ask permission from the original sender. Once an e-mail is sent or forwarded, there is no control over what a recipient may do with it. This can lead to the unintended disclosure of personal information or confidential information. Be prudent about e-mail messages that are sent or forwarded and what is attached.

Avoid use of e-mail to transmit sensitive personal or confidential information. If e-mail must be used to communicate, it is critical to minimize the consequences of unintended disclosure (e.g., by disclosing only some information, by deleting personal identifiers, or deleting all e-mail trail).

Verify the e-mail addresses of recipient(s)

Avoid using the "reply to all" feature

E-mail Guidelines

As the confidentiality of e-mail cannot be assured and such confidentiality may be compromised by unintended redistribution, all EAP staff must follow e-mail guidelines governing the use of the subject line and the addition of a confidentiality footer within the text of an e-mail.

Note that when sending mass e-mails, you must use the "Bcc" line. This is for security and privacy reasons because many e-mail providers spam messages with multiple addresses in the "To" line and because some students do not give consent to share their e-mail addresses with others.

Subject Line for Non-confidential Matters

The subject line should read as follows: "[Name of student]-[Country, Program Name]." For example, "John Smith-France, Lyon Year."

Subject Line for Confidential Matters

For confidential matters, such as health or disciplinary actions, the name of the student should not be included in the subject line; however, it can be used in the body of the e-mail.

The subject line should read as follows: "CONFIDENTIAL-[Topic]." For example, "CONFIDENTIAL-Letter of Reprimand, Student at HKU Fall 1011," or "CONFIDENTIAL-Psychotropic Information."

Confidentiality Footer

The use of an e-mail confidentiality footer serves as a reminder that EAP values the privacy of e-mail communication. It also serves a practical purpose if there were ever a records request for these e-mails, since the confidentiality footer identifies messages as potentially containing private information. It should be noted that the existence of the footer probably would not change the legal analysis of whether any particular message contained private information-either the information is private or it is not, and the footer cannot make it private if it is not. UOEAP will include a confidentiality footer in all e-mail correspondence about a student, regardless of whether the communication is confidential. This footer should read:

***E-mail Confidentiality Notice***

This e-mail and any files transmitted with it may contain privileged and confidential information subject to privacy regulations. This information is intended solely for the use of the individual or entity to which it is addressed. If you have received this message in error, please notify us and remove it from your system.

605.02 Correspondence with Campus EAP Offices

With EAP locations in 35 countries worldwide, knowledge sharing, efficient communication protocols, and collaboration between the on site and US teams is critical for successful EAP operations. Academic and Operations Specialists in the regional teams at UOEAP serve as liaisons between Campus EAP Offices and Study Centers. This helps EAP to 1) coordinate activities and the sharing of accurate information among different constituents; 2) limit EAP's legal exposure by providing one consistent and centralized forum for the exchange of information; and 3) provide updates of new information, policies, and procedures. Therefore, all communication among the Study Centers and the campuses that involves discussion, interpretation, or decisions regarding policy and procedures must be routed through UOEAP. Specialists at UOEAP serve as the liaison with the Study Centers to coordinate issues between the host university and Study Center and each UC campus. This communication approach still provides a timely and consistent response and enables consistent action and follow-through, as necessary and appropriate, by UOEAP staff.

Communications concerning the application of an individual student's EAP course work to home campus departmental or college requirements or course registration for return to the home campus may be directed to the appropriate campus staff without routing through UOEAP. (See the charts for EAP campus contacts on EAP's Contact Information web page.) It is recommended that the relevant Academic Specialist be copied on these communications as it is helpful for staff at UOEAP to know how EAP course work is applied at the campuses.

605.03 Telephone

Lists with UOEAP and campus EAP staff phone numbers and rosters with full information on contact points for all Study Centers are available on EAP's Contact Information web page.

605.04 Communications with Parents and Other Relatives

FERPA (Family Educational Rights and Privacy Act), State of California privacy laws, and the UC systemwide policy do not allow disclosure of student information to parents without the specific written consent of the student.

UOEAP and the SC Director must have written permission from the student to talk to parents or other relatives, including the disclosure of whether or not the student is an EAP participant.

See Section 600.00, Student Records for more information.

UOEAP acts as the conduit of information between relatives of students and the Study Center. UOEAP's business practice approach is not to give out information to anyone on the phone claiming to be a parent or relative of a student. Therefore, if the SC Director receives correspondence or telephone calls from parents or other family members, the SC Director should inform the relative that he or she will investigate the matter and will call the parent or relative back. It is the student's responsibility to keep parents informed about his or her well-being, academic record, etc. The SC Director must obtain written permission from the student to discuss the student's personal life, financial status, academic program, progress, or records with anyone. If the student chooses not to inform the parent or relative, the SC Director may not do so unless it is a health or safety emergency. If the matter goes beyond answers to routine questions, the SC Director should send the reply to UOEAP for discussion with the relative.

The SC Director should keep UOEAP informed of any ongoing discussions with a relative.

Exceptions to this policy for all students are health and safety emergencies in which the student is incapacitated (such as by a life-threatening illness or accident) and is unable to inform the parent, give informed consent for personal treatment, or give permission for the SC Director to contact his or her parents. If the student is incapacitated and the SC Director believes his or her own response is in order, the SC Director should communicate with UOEAP.

605.05 Communicating during an Emergency

In the event of an emergency, such as a natural disaster or political upheaval in the Study Center country or region, the SC Director should contact all participants to ascertain their well-being and to alert students to contact their parents, partners, relatives, or emergency contacts as soon as possible. The SC Director should be able to account for all students (even if the natural disaster takes place in a different part of the country) and notify the Regional Director at UOEAP as soon as possible even if he/she cannot account for all students. UOEAP will then inform the Campus EAP Offices and EAP students' parents as appropriate. SC Directors should bear in mind that family and friends of program participants may not have a clear understanding of host country geography; an event such as an earthquake may cause alarm even if it takes place several hundred miles from the program site.

Additional steps to take in emergency situations are included in the Study Center Emergency Preparedness Handbook. The home phone numbers and cell phone numbers of key UOEAP staff to contact during an emergency (if it occurs outside office hours) are listed in the Study Center Emergency Preparedness Handbook and are regularly updated on the EAP Emergency Contacts web page. In addition, the SC Director must provide UOEAP with his or her home and cell phone number.

UOEAP maintains a public emergency web page to inform families about the process to follow when they are concerned about a health or safety emergency for an EAP student currently abroad. Twenty-four-hour contact information is provided for the UOEAP office. The page periodically includes communiqués on EAP's position during major international events that affect EAP as a whole.

605.06 Safety and Incident Reporting

The SC Director must immediately complete and send to the Operations Specialist a Safety and Incident Report (available in both writeable PDF and Word formats) for any crimes or incidents reported by a student that involved bodily harm, the threat of bodily harm, or racially motivated verbal or physical harassment. Note that stalking behavior should be considered an incident that involves threat of bodily harm, even if no direct threat is verbalized.

Robbery (defined as the taking or attempting to take anything of value under confrontational circumstances from the control, custody, or care of another person by force or threat of force or violence and/or by putting the victim in fear of immediate harm) and burglary (defined as the unlawful entry into a building or other structure with the intent to commit a felony or a theft) must be reported on a Safety and Incident Report. As with any form of major crime, the report should be completed and submitted to the Operations Specialist as soon as possible after the incident occurs.

A separate Safety and Incident Report does not need to be completed for individual instances of minor street crime, including petty theft like pick-pocketing (a form of street crime that causes little objective damage but a great deal of alarm). A summary of all such known instances that happened during the year must be reported on the Annual Safety and Incident Report. However, as with any crime, students who are victims of petty theft should be encouraged to file a report with the local police.

If there is any doubt about whether a form should be filled out, the SC Director should err on the side of completing a form or contact the Operations Specialist at UOEAP. SC Directors should keep the Regional Director and Operations Specialist informed and updated about the nature and urgency of each student incident abroad. It is essential to hear first from the Study Center before parental or media contacts start.

As an appendix to the Annual Report, the SC Director should complete a more detailed Annual Safety and Incident Report that summarizes incidents that took place over the course of the year.

605.07 Communication Guidelines: Infectious Diseases

Listed below are EAP guidelines for communicating about infectious diseases. These guidelines are based on EAP's experience dealing with past health-related outbreaks. They will be reviewed and updated as new information becomes available.

EAP's goals regarding all communications are to:

· Provide students, parents, and staff with one reliable source for timely, factual, accurate, and official information to help them keep a balanced perspective.

· Use the EAP public emergency web page as the official EAP source for information on infectious diseases and other risks. The Principal Analyst will be responsible for content and will work with UOEAP's Design and Editorial (D&E) and Information Technology (IT) staff to keep the site accurate and current.

· Make sense out of the clutter of information in the public domain through the media, Internet, etc. The immediacy of the Internet and e-mail makes this goal critical.

· Address individual concerns as fully as is feasible.

· Provide program-specific information if program changes are made as a result of infectious diseases.

· Coordinate the release of information about the impact of infectious diseases and other health risks on EAP programs to the public press.

EAP's step-by-step plan follows:

1. The UOEAP Principal Analyst will continually monitor, assess, and disseminate relevant information, consulting sources including WHO, CDC, and other reliable websites.

2. After consulting with the appropriate Regional Director and staff at UOEAP, the Principal Analyst will prepare updated information for the EAP website and will share all critical information with the Study Center by alerting them to important information updates on the EAP website.

3. The Principal Analyst will alert regional staff about updated information and staff will relay it to the campuses (program advisors) with any additional program-specific information that may be appropriate. The Principal Analyst will e-mail CAD and CCD.

If possible, the SC Director will need to work closely with EAP regional staff and the Principal Analyst on all communications to students relating to major infectious diseases. It is crucial that the SC Director consult with UOEAP as appropriate before sending anything about these matters to students, parents, or other public venues.

605.08 Study Center Files: Retention of Material

To maintain continuity, it is necessary to keep general Study Center correspondence, Registration Study Lists, petitions, and grades at the Study Center for three years. Any material that might be of help to an incoming SC Director should also be retained. Files on students are kept at UOEAP for five years. The SC Director should forward specific information to UOEAP on particular students if the SC Director feels the information should be incorporated into the student's UOEAP file.

610. INFORMATION TECHNOLOGY (IT) SUPPORT

610.00 Information Technology (IT) Study Center Support

For IT Study Center support information on hardware and software procurement, inventory management and licensed software downloads such as Antivirus and Office 2003, visit the IT Study Center Support web page. Check the page regularly for updates.

If you have questions or comments about this site or need technical assistance, contact the IT Support Liaison for Study Centers at scsupport@eap.ucop.edu.

615. STUDY CENTER DIRECTOR'S REPORT

615.00 Study Center Director's Report

See Section 235.00, Annual Report.

620. ILP REPORT

620.00 ILP Report

See Section 235.01, ILP Reporting.

625. ACADEMIC PROFILES

625.00 Academic Profiles

See Section 235.05, Academic Profiles.

630. EAP RECRUITMENT, ADVISING, AND ORIENTATION MATERIALS

630.00 EAP Websites

UOEAP maintains an extensive website that contains:

· Country and program information

· Host institution descriptions

· Discipline-specific information

· Forms used before program departure and during the year

· Student testimonials

· Photos

· Videos and multimedia projects

· Program contact and emergency information

· UC information and links to the UC campus and campus EAP home pages for students coming to UC

The Campus EAP Offices maintain websites that contain information specific to campus operations. They link to the UOEAP website for program information.

All SC Directors and EAP students are encouraged to send information they consider useful for prospective EAP participants to UOEAP for possible inclusion in the UOEAP website.

630.01 Recruitment and Orientation Materials

SC Directors are asked annually to provide input for EAP orientation materials (e.g., Program Guides and participation forms and instructions). It is critical that the SC Director thoroughly reviews the material and responds with his or her comments and revisions by established deadlines.

SC Directors and students are encouraged to provide UOEAP with photographs for use in publications and the UOEAP website depicting:

· The academic environment (university buildings, classes, labs, library, or the Study Center and staff)

· EAP excursions and program activities

· Students engaged in fieldwork and research

· Typical housing, living environments, and transportation used by EAP students

· The city environment and famous landmarks

· Cross-cultural activities

In addition, UOEAP welcomes recruitment materials describing the host university and city in published and audiovisual formats. Materials that the SC Director thinks would be useful in recruitment and in sustaining an applicant's interest should be sent to UOEAP in sufficient quantity for UC campus distribution.

630.02 Student Highlights/Testimonials/Articles

Student stories and comments on the value of EAP are featured throughout EAP's website and in various publications. SC Directors are requested to identify students who have had positive experiences on the program and encourage them to e-mail their experiences to UOEAP (D&E@eap.ucop.edu). In addition, UOEAP may contact students to solicit stories, comments, and photos.

630.03 News Releases

EAP occasionally sends out newsletters to EAP staff that highlight student, staff, faculty, Study Center, or program innovations, awards or achievements. SC Directors are asked to submit newsworthy articles to the Director's Office at adelap@eap.ucop.edu. Articles that have broader appeal to the UC community may also be used in newsletters that will have a systemwide distribution.

630.05 Host Institution Academic Calendar

Academic program calendars are used at UOEAP and in a number of offices on the campuses. The calendars must include beginning and ending dates for all program options, the arrival and EAP orientation dates, the ILP schedule, term breaks and vacation dates, exam periods, and important multiple-day holiday dates recognized by the host country.

Each year SC Directors are requested to provide dates to the relevant Operations Specialist for the following year. At Study Centers where actual host institution dates are not available at the time requested, SC Directors should provide their best projections for the following year based on the current year's academic calendar and then forward verified dates to the Operations Specialist as soon as they are known.

630.06 Logos

Study Centers may use the unofficial seal of the UC and/or EAP logos on official Study Center materials, accessible on the Logos page of EAP's Shared Resource Library.

635. STUDY CENTER WEBSITES AND ELECTRONIC COMMUNICATION

Many Study Centers rely on web-based communications to keep in touch with students currently on the program. These may take the form of websites, Facebook and other social networking sites, or blogs. Study Centers may receive limited support from UOEAP to create such sites, subject to available resources at UOEAP and to capabilities of individual Study Center staff.

640. CATALOGS/UC PUBLICATIONS

640.00 Host University Catalogs

SC Directors should be practiced at finding and sharing relevant information from online host university catalogs. Changes or difficulties with such catalogs should be communicated to the relevant Academic Specialist at UOEAP. If the SC Director believes that a hard-copy catalog has particular interest or informational value, a copy should be forwarded to the Academic Specialists via surface mail.

640.01 UC Campus Catalogs/UC Directory

UOEAP rarely mails reference publications abroad. UC catalogs and schedule of classes can be accessed via the UC campus websites. Contact information for UC faculty and staff is accessible online in the UC Directory.